IR 05000213/1991001

Insp Rept 50-213/91-01 on 910107-11.No Violations Noted. Major Areas Inspected:Radiological Controls Program on Site, Including Organization & Staffing,Tours of Facility,Review of Audits & Appraisals & Internal Exposure Control

ML20029A225
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	01/23/1991
From:	Oconnell P, Pasciak W, Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20029A222	List: IR 05000213/1990001 IR 05000213/1991001
References
50-213-91-01, 50-213-91-1, NUDOCS 9102050084
Download: ML20029A225 (12)

Text

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S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

50-213/91-01 Docket No.

50-213 License No.

DPR-61 Licensoo: Connecticut Yankee Atomic Power "smoany Facility Name: Haddam Neck Power Station Inspection At: liaddam Neck, Connecticqt Inspection Conducted: January 7-11. 1991 Inspectors: l/ M2h, [[/V-7/ ' P.

O'Connell, Radiation Specialist dato Pacilitios Radiation Protection Section c-q_,.

d /A1 -tv i I [~2 7 h// S.

Sherbini, Senior Radiation Specialist date Facilities Radiation Protection Section Approved by; A>. I f24 / 23-9/ W.

PaseThk," Chief, Facilities Radiation dato ' ' Protection Section Inspection Summary: Inspection conducted January 7-11, 1991 (Inspection Report No. 50-213/91-01).

Areas Inspected: Routino, unannounced inspection of the radiological controls program on site, including organization and staffing, tours of the facility, review of audits and appraisals, internal exposure control, instrument calibration, and review of selected procedures.

Results: Within the scope of this inspection, no violations were identified.

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. DETAILS 1.0 Personnel Contacted 1.1 Licensee Personnel

• W.

Gates, Assistant Radiation Protection Supervisor R. Groves, Radiation Protection Specialist S.

Lavoie, Senior Technician R. McGrath, Senior Engineer

• W.

Novelos, Radiation Protection Supervisor, Operations

• M. Quinn, Manager, Chemistry
• J.

Romine, Health Physics Technician

• D. Roy, Director, Nuclear Services
• H.

Siegrist, Supervisor, Radiation Protection Section, RAB L. Silvia, Health Physicist

• J.

Stetz, Station Director

• M.

Sweeney, Radiation Protection Supervisor, Services A. Vomastek, Assistant Radiation Protection Supervisor 1.2 NRC Personnel

• A. Asars, Resident Inspector
• Denotes attendance at the exit meeting.

2.0 Status of Previously Identified Items 2.1 (Closed) Noncompliance Item (89-22-01): This item addressed the finding that there was no formal retraining program for the health physics (HP) staff on site other than HP olerations technicians. Such retraining is required by T(chnical Specifications 6.4. Although the HP staff was N ing trained on a regular basis, such training was not i incorporated as part of a formal program, and was therefore not predictable in terms of its effect on the continued updating of the technical capabilities of the staff.

The licensee, in response to this finding, developed a procedure to address the issue of training of HP personnel.

Procedure RPM 1.2-4, " Exempt Personnel Training" establishes a formal training program for HP personnel not included in the regular HP technician retraining program. According to this procedure, the retraining is to be done at several levels as follows: l . . . ... . .. .

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, . I o A daily meeting is to be held by HP management with the HP exempt personnel to discuss pertinent issues, significant occurrences both at the site and in the industry, and upcoming projects or issues.

o once a month, a member of the exempt HP staff is assigned to give training to the other exempt staff on a topic of interest. The training is to be given during the daily morning meeting.

o Annually, each exempt HP staff member is to participate in at least one of the following: a station committee, such as the ALARA committee, PORC meetings, outage planning meetings,-or other special projects meetings. In addition, the staff member must attend at least two of the following management development course, technical training course in a relevant topic, professional society meeting or seminar, or a utility systems training course (a two-week course).

There are currently twelve exempt personnel who will be affected by this procedure. The training schedule and a record of completed training is being maintained by one of the exempt staff. A review of the documentation for this program showed that it is being satisfactorily implemented.

This issue is therefore considered closed.

2.2 (Closed) Follow-up Items 82-27-01 and.f0-11-01: This item refers to the status of actior. taken in response to IE Bulletin 80-10, " Contamination of Nonradioactive System and Resulting Potential for Unmonitored Release of Radioactivity to the Environment". NUREG/CR-0302, " Closeout of IE Bulletin 80-10", published in 1990,-indicated that.Haddam Neck was the only licensee that had not yet completed the required action in response to the Bulletin. The item preventing closure of the Bulletin was documented in NRC Inspection Report 50-213/81-11. It refers to the fact that the licensee's report on Bulletin actions was considered incomplete because it did not consider the potential for contamination of non-liquid systems, such as the instrument air and nitrogen systems. The NUREG also mentions a recent-incident at Haddam Neck in which an unmonitored radioactive release pathway was_ discovered on site, The issue,was reviewed during this inspection. The licensee i stated that the non-liquid pathways were reviewed for possible contamination during preparation of the original i i l t.

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study. The results of that study were issued in a licensee report No. EN-MO-153, " Contamination of Nonradioactive , ' System and Resulting potential for Unmonitored, and Uncontrollable Release of Radioactivity to Environment, IE Bulletin No. 80-10, CRP 80-342", dated May 27, 1980. The licensee stated that the non-liquid systems were not mentioned in that report because the probability of contamination of these systems was considered to be so small that they were, in effect, regarded as not potential pathways for release of radioactivity. A memorandum to that effect was issued during this inspection from the Engineering Department to the Manager, Chemistry. The memorandum, No. EN-91-0031, was dated January 10, 1991.

The non-liquid systems at issue are the control and service air system and the nitrogen system. The control and service air system supplies air at 90-100 psig to various components in the primary and secondary sides of the plant. The source of compressed air is three compressors located in the turbine building, with their intakes tiso drawing air from the turbine building air. The licensee stated that it is unlikely for this system to become contaminated partly because it operates at high prescure and therefore would prevent in-leakage from lower pressure systems, but also because there is no direct pathway between the air supply system and contaminated systems within the plant. For example, air would be supplied to an air operated component, but the air system would connect only to the air actuation mechanism of that component and not to the contaminated fluids controlled by that mechanism. The nitrogen system consists of a bank of high pressure nitrogen cylinders located on site in the yard area, within the radiological controls area (RCA). They are connected to the delivery locations in the plant by lines and the '1^w is controlled , by pressure regulators and check valves, check valves ensure flow in one direction. The nitro ( ystem is used to provide an inert blanket during wet layup n the steam generators and is also used in the volume control system.

Nitrogen is also used as a purge gas in some systems such as the generators and the coolant loops.

Another concern about unmonitored release pathways was raised in a recent NRC Inspection Report. NRC Inspection Report 50-213/90-11 noted that iodine-131 was recently detected-in vegetation samples taken from areas close to the plant, and it suggested that the results may indicate an l l- . _ _ ._ _- -. . _ --

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I k U unmonitored release pathway. However, a review of the recent ' sampling and effluent release data indicated that the results can be adequately explained by recent releases of

noble gases and iodines which were higher than usual. These releases occurred following reactor shutdown in September of .1989 in preparation for a refueling outage, and were done in preparation for disassembling the reactor. A review of the offluent relecse data showed that iodine was released in the offluents during the period from September 3, 1989 to the end of September 1989, with a total of 1.35E-2 curies released during the third quarter and 1.42E-3 curies released during the fourth quarter of 1989. Elevated levels of noble gases were also released during the same period.

The licensee stated that the purge period following shut down was extended from soveral days, which is the normal duration, to over three wooks because of the elevated levels of noble gases and iodines in the system. The licensee stated that the clovated levels were anticipated because of the significant number of fuel cladding defects that occurred during the operating cycle (Cycle 15). The licensee stated that although the cladding damage had occurred throughout the operating cycle, significant releases of noble gases and iodines from the fuel did not occur until after the system was shut down and depressurized. As a result of the anticipated releases, additional environmental samples were taken during the venting period. Milk samples did not show any lodines, mainly because of the relatively long distance of the sampling locations from the plant.

Vogetation taken close to the site bounda.y did show iodine during September.

A review of the recent discovery of an unmolitored release

pathway (NRC Inspection Report 50-213/89-02) showed that the pathway had been identified in the licensee'a 1980 report.

The pathway was from the Spent Fuel Pool Heat Exchanger to a floor drain in the Spent Fuel Building. The drain discharged into an open trench surrounding the 115 kV transformer area in the yard on site. The trench discharges either to a yard storm drain or to a sandy area outside the site fence. The sandy route represents an unmonitored release pathway that ends in the Connecticut River. The licensee estimated that slightly over 1 millicurie of cobalt-60 was spilled into this sandy area from that pathway.

The licensee stated that the pathway from the Spent Fuel Building had been isolated after it was identified in 1980 -,. .-- . -. .- - - . .. -.

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1 i by plugging the pipe leading from the floor drain to the outside of the building. The licensee also stated that , between 1980 and 1989, the plug had been inadvertently removed, thus re-opening that pathway. The licensee stated , l that a plug has been ro-installed on the pipe and has been welded to prevent inadvertent removal. In addition, the " licensee has developed a procedure to improve the monitoring - program for all pathways that Icad to the environment. The , procedure is SUR 5.4-18, " Surveillance of Unmonitored Potential Radioactive Release Paths and Continuous Dischargo". According to this procedure and the revised ' station policy on floor drains, all uncontrolled drains in 4. the primary side of the plant are to be plugged and labelled to prevent use for draining any fluids without permission from the Chemistry Department. Chemistry is to sample all fluids for radioactivity before allowing the plug to be opened for discharge. A similar policy will be in effect on , -the secondary side of the plant. In addition, a surveillance program was developed to ensure that all pathways to the environment are monitored at appropriate frequencies to ensure that these systems have remained uncontaminated. In view of these actions, the probability of creating an unmonitored release pathway is considered very small, and this item is therefore considered closed.

3.0 oraanization and Staffino:

A review of the organization and staffing levels of the health physics departmont showed that there has been no ' change in the organizational structure and very little change in the personnel filling the various positions within the-organization. The staff remains stable with very little turnover, which is consistent with previous findings in this area. There have been changes in the personnel occupyit.g upper management positions on site. The two positions that directly affect the health physics department, namely the ! Station Director and Station Services Director, are now p occupied'by newly appointed personnel, both from outside the L site organization. These appointments are recent and it is l too early to assess the;; impact on radiological performance on site.

l 4.0-Ingrg: The inspector conducted several tours of the RCA. All areas were posted, barricaded or locked as required. Housekeeping _ _- , _ _ .- ~. - _ _..__ _ _ _ _,.

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throughout the RCA was good. The inspector independently took radiation survey measurements. All measurements were in agreement with postings and documented survey results.

The inspector noted that the licensee was controlling access to the Spent Fuel pool (SFP) storage area in the same manner as locked High Radiation Areas, i.e. areas where the general area dose rate exceeds 1000 mrem /hr. The licensee stated that they recently began controlling access to the SFP area in this manner because of the presence of several items hanging, underwater, from the edge of the SFP. The licensee has a long term goal to remove and dispose of items stored in this manner. The licensee's short term goal is to survey all such items and lock in place those items which would generate general area dose rates in excess of 1000 mRom/hr if removed from the pool. The licensee stated that they would continue to control access to the SFP area until all items were surveyed and locked as applicable. This is considered a good initiative.

5.0 Audits and Anoraisal: Several levels of audits were performed by the health physics organization, in addition to Quality Assurance (QA) audits.

o Technician Assignment Reviews: HP technicians are assigned to observe an ongoing job and evaluate the adequacy of radiological controls and ALARA. The results are recorded on a standard review form and are reviewed by HP management.

About 30 such reviews are assigned per year.

o Department Audits: These audits are conducted to review certain segments of the program, the topic frequently being determined by current industry or site concerns or events.

About 12 of these audits are performed per year.

o Health Physics Appraisals: These are similar to the Department Audits but are of greater technical depth and are performed by the site Health Physicist. About four such audits are conducted per year, o Corporate Appraisals: These appraisals are conducted by corporate health physics personnel, and they review one or more segments of the site program each appraisal. The appraisals are scheduled so that all segments of the site !

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8 , program are reviewed in a three-year cycle. Two such appraisals would normally be scheduled each year, although only one was conducted last year because of a temporary shortage of corporate staff. The last appraisal conducted was on ALARA.

Audits and appraisals performed recently by the licensee were reviewed. They were found to be of good quality and of sufficient depth to identify problems in the program segments being audited.

6.0 Internal Exoosure Control: The inspector reviewed the licensee's program for determining airborne concentrations of radioactive material.

. The inspector reviewed licensee procedures RPM 2.2-5, " Airborne Radioactivity Surveys", and RPM 2.2-7, " Air Sample Counting". The procedures were well written and technicians implementing the procedures were knowledgable of the procedure requirements. The inspector noted that the procedures contained such prerequisites as specifying minimum sample volumes for the different types of air samplers utilized at the facility. By establishing a minimum sample volume the licensee is able to ensure that an acceptable lower limit of detection is always achieved. The licensee's air sample counting procedure contained similar prerequisites by establishing minimum count times, based on daily background counts, in order to achieve an acceptable lower limit of detection.

The inspector reviewed selected air sample count data.

Reviewed results indicated that the_ licensee was effectively minimizing airborne radioactivity concentrations in most areas of the facility.

The inspector toured the licensee's whole body ccunting facility. The licensee recently upgraded their whole body counting capabilities with the installation of-a new, quick-scan, whole body counter. The count time for the new counter is much shorter than_the time required for the previous chair type of counter. The licensee also has a bed type whole body counter for diagnostic counting._A review of whole body count results indicated that personnel intakes of radioactive material were extremely low. The results were consistent with air sample results which indicated low . - -,- - - - . -, - ._ _ . . . - -.

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concentrations of airborne radioactivity.

The inspector reviewed the licensee's quality assurance for the whole body counters. Source checks of both whole body counters are conducted daily. The results are plotted on control charts for trend analysis. The licensco also participates in a program in which, on a quarterly basis, a vendor sends the licensee blind spike samples for analysis.

Overall, the licensee had an excelent quality assurance program for the whole body counters.

The licensee's bioassay program to monitor personnel exposures to tritium was reviewed. The licensee's procedure specifies urinalysis for tritium anytime an individual is exposed to greater than 10 MPC-hours in any week. In 1990 the licensee sont 62 urine samples to a vendor for tritium analysis. The inspector reviewed selected urinalysis results and personnel exposure records and determined that the licenseo had an effective program for monitoring and documenting personnel exposures to tritium.

The inspector toured the licensee's respirator maintenance l and issuance facilities. The licensee has adoquate facilities and procedures for the maintenance and issuance of respiratory protection devices.

The licensee has an excellent program to verify the offectiveness of the air sampling and respiratory protection program. On a weekly basis, a percentage of the individuals who had worn respiratorv protection devices are sent for whole body counts. Monthly, selected individuals who had not worn respiratory protection devices are also sont for whole body cou.nts. The station Health Physicist reviews the whole body counts and applicable air sample results to periodically verify the effectiveness of the air campling and respiratory protection program.

, Overall, the inspector concluded that the licensee had an effective internal exposure control program. Supervisory oversight of the program was excellent.

7.0 Instrument Calibration: Calibration of survey instruments, friskers, portal monitors, and air sampling equipment was reviewed by reviewing selected calibration records, touring the l l . _..... _ _.

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i l i calibration facilities, and reviewing applicable procedures.

Calibration records were found to be complete and clearly ' documented, and the calibration procedures were found to be j well written and easy to follow. There was no change in the calibration facility from previous inspections. This facility is located in a trailcr in the RCA yard. The licensoo stated that space within the recently completed Switchgear Building adjacent to the Primary Auxiliary Building has been identified to house an improved calibration facility. However, a tour of the identified space showed no indication of preparations for installation - j of a calibration facility.

l 8.0 Procedures: . ! A number of selected procedures relevant to the areas F inspected were reviewed. The proceduros woro found to be of uniformly high quality, well written, easy to follow, and ' ' complete. Somo items for improvement and some errors were identified in some of the proceduros, however. Those items , are as follows.

' iJ o Procedure RPM 2.2-11, "Noblo Gas Exposure" providos a work sheet for calculating bota skin and whole body donos resulting from immersion in a cloud of noble gas based on i gas isotcpic analysis data. The whole body dose is calculated for Kr-87, Kr-88, Rb-88, Xo-138 and Cs-138. Those

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isotopes omit bota radiation sufficiently energotic to ' penetrate to the lens of the eye. However, the calculation i of skin dose does not include these isotopes amongst the isotopos that should be considered in calculating beta skin ' doso. The inspector reviewed the assessments of skin exposures from noble gases from the last several containment power entries. The calculated skin dose rato for containment power entry with the highest concentration of noble gases was approximately 4 mrad /hr. The inspector calculated the skin dose rato for the containment power entry using all applicable isotopos. The skin dose rate was approximately 10 !. mrad /hr. The licensoo stated that the procedure error will be corrected.

o Proceduro RPM 2.2-11 also states that skin dose resulting from immersion in a noble gae cloud is to be assigned on the l basis of thermoluminescent dosimoter (TLD) readings.

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However, observation of preparations for a containment power entry during this inspection revealed that there was confusion amongst the workers and also the HP technicians regarding the proper placement of TLDs. Some believed they should be placed inside the protective clothing and others believed they should be placed outside. The procedures do not provide guidance on this point. The licensee stated that they will correct this situation by appropriate training and procedure revisions.

o High efficiency particulate air filter (HEPA) portable units are used in several situations to minimize airborne radioactivity in work areas where such radioactivity may be generated. However, these units are not normally tested to ensure that the HEPA filter is in the unit, is properly seated, and is filtering efficiently. The procedures do not require such testing. The licensco stated that in many cases where such units are used, the output from the unit is taken directly to the station ventilation system, and in such situations, the efficiency of the filter is not critical.

The licensee stated that they also routinely sample the output flow from these units, and that in many cases, a real time air monitor is also in use nearby. The licensee also stated that they will consider revising their procedures to require testing of the units whenever maintenance is performed or when the filter is replaced.

o Procedure RPM 2.4-2, " Respirator Fit Testing" states that the Fit Factor (FF) and the Protection Factor (PF) mean the same thing. However, this is incorrect, the fit factor applying to respirator fitting and the protection factor applying to the degree of protection that a respirator is thought to provide when used in the field. Respiratory protection practice requires that the fit factor exceed the protection factor by a substantial margin. The licensee is using a fit factor of 200 for negative pressure respirators, for which the protection factor is 50. The licensee stated that they will review and correct the procedure.

o Procedure 2.2-11, " Noble Gas Exposure" specifies that eye g protection must be used under certain conditions when working in a cloud of noble gases. The procedure lists

varicus acceptable eyewear but does not specify the minimum acceptable thickness for the eyewear nor does it provide for means to ensure that the selected eyewcar, which is not standard issue, is sufficiently thick.

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o Procedure RPM 4.2-3, " Calibration of E-140 with Frisker Probe" does not require an efficiency check on the probe unless it is to be used in an emergency kit. The reason for this is not clear since checking of probe efficiencies is standard practice during instrument calibrations on site.

The licensee stated that they will review the r..atter and make appropriate revisions to the procedure.

9.0 Exit Meetina: A meeting was held with licensee representatives at the end of this inspection, on January 11, 1991. The purpose and scope of the inspection were reviewed and the inspection findings were discussed during this meeting.

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